US ITAR and EAR - Export Control and Data Security
Controlled technical data and technology: exports, releases and access – US ITAR and EAR - Export Control and Data Security

US ITAR and EAR - Export Control and Data Security ITAR 120.55 and EAR 734.19: Treat decryption keys, passwords and other access information as controlled

Access information is information that lets someone reach encrypted technical data in unencrypted form, such as decryption keys, network access codes and passwords (120.55). Giving access information to a foreign person requires the same authorisation as releasing the underlying data where it can enable access, viewing or possession of the unencrypted data (120.56(b)); under the EAR a comparable authorisation is needed to transfer access information with knowledge that it will result in an unauthorised release of technology or software (734.19(a)). Software licence keys are classified under the same ECCN as the software or hardware they unlock, so a licence requirement that later attaches to the item (for example an Entity List addition) attaches to later key transfers too (734.19(b)).

Maintained by Gerard BlokdykVerified against the published standard Control text last updated

What else in your programme already covers this

This control maps to 2 controls across 1 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.

  • 734.17 734.17 Export of encryption source code and object code software
  • 734.19 734.19 Access information and software keys

Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected.

Other controls in Controlled technical data and technology: exports, releases and access – US ITAR and EAR - Export Control and Data Security

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